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ESR, advocated by the Organisation for Economic Cooperation and Development, will replace the thin capitalisation legislation and are proposed to be effective from January 2019.  Given that the ESR will be operative in less than 12 months, we are attaching an article which provides a broad outline of how the ESR may work and the associated issues to be considered for your attention.

If you wish to discuss the potential impact of ESR on your company, please do not hesitate to contact any of our Executive Directors, Directors, Associate Directors or Managers whom you are accustomed to dealing with or who are responsible for the tax affairs of your organisation at the telephone number (603) 7721 3388.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.